Financial Crime Compliance Director

Il y a 10 heures

Brussels, Brussels-Capital, Belgique Anchorpoint Temps plein
About Anchorpoint Anchorpoint Financial Limited is a subsidiary of Standard Chartered Bank (Hong Kong) Limited (SCBHK) and a joint venture established by SCBHK, HKT, and Animoca Brands in February 2025. With the vision of utilising tokenised money to rewire and supplement existing financial infrastructure for the betterment of the real economy, the initial goal is to build and advance the regulated HKD stablecoin “HKDAP” to serve as a secure tokenised medium of exchange for digital economy and to facilitate international payments and capital flows. It is one of the first entities granted with a stablecoin issuer licence (licence number FRS01) by the Hong Kong Monetary Authority under the Stablecoins Ordinance in April 2026.

Job Description
The FCC Director / Compliance Manager is responsible for establishing, maintaining and enhancing the firm’s Financial Crime Compliance framework and supporting compliance with the Stablecoins Ordinance (Cap. 656), the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615), applicable HKMA guidelines, sanctions requirements, anti-bribery and corruption obligations, fraud prevention requirements and broader financial crime risk management obligations. The role sits within the Risk & Compliance function reporting directly to the Compliance Officer. The role provides independent second-line oversight and challenge and supports senior management and the Board in maintaining an effective control environment and meeting relevant legal and regulatory requirements. The role also serves as Deputy Money Laundering Reporting Officer (Deputy MLRO), supporting the MLRO in the assessment, decision-making and reporting of suspicious transactions.

Key Responsibilities
Financial Crime Compliance Framework
• Develop, maintain and periodically review the FCC framework, policies, standards, procedures and controls.
• Ensure FCC arrangements remain aligned with applicable laws, regulations, regulatory guidance and industry practices.
• Lead implementation of a risk-based approach across FCC activities.
• Conduct periodic FCC risk assessments and recommend enhancements to address identified risks.
• Oversee AML/CFT, sanctions, fraud, ABC and other relevant financial crime risk areas.
• Act as a subject matter expert on AML/CFT obligations and regulatory expectations.
• Oversee customer due diligence, enhanced due diligence, ongoing monitoring and periodic review processes.
• Review and approve high-risk customer relationships in accordance with delegated authority.
• Assess customer, product, geography, delivery-channel and transaction risks.
• Oversee transaction monitoring, investigation and suspicious activity escalation processes.
• Oversee the preparation and submission of suspicious transaction reports where required. Deputy MLRO and Suspicious Transaction Reporting
• Receive and assess internal suspicious transaction reports and other financial crime escalations, determine whether further investigation is required and make recommendations to the MLRO on external reporting.
• Lead or oversee financial crime investigations, ensuring that relevant transaction activity, wallet exposure, customer due diligence, client risk factors, source of funds, source of wealth and supporting evidence are appropriately considered and documented.
• Prepare and, where authorised under the applicable delegation, submit suspicious transaction reports to the Joint Financial Intelligence Unit in a timely manner, while maintaining confidentiality and managing tipping-off risk.
• Maintain complete records of internal reports, investigations, reporting decisions, external filings and post-filing risk-management actions.
• Coordinate post-STR actions, including enhanced monitoring, CDD trigger reviews, additional risk-mitigation measures, account restrictions, relationship review or exit recommendations, as appropriate.
• Provide management information and escalation on investigation themes, typologies, reporting volumes, control gaps and remediation actions.
• Lead the review and investigation of complex transaction monitoring, screening and on-chain monitoring cases escalated by the first line of defence. First-Line Advisory, Review and Capability Building
• Provide practical advice, review and hands-on support to first-line teams on FCC matters, including onboarding, CDD, screening, transaction monitoring, investigations, escalation and remediation.
• Review and challenge first-line risk assessments, case files, alert dispositions, CDD records, enhanced due diligence and high-risk relationship recommendations.
• Support first-line teams in developing and maintaining procedures, desktop instructions, investigation templates, escalation standards and control evidence. Stablecoins Ordinance and Licensed Issuer Requirements
• Act as a subject matter expert on the Stablecoins Ordinance (Cap. 656), the HKMA Guideline on Supervision of Licensed Stablecoin Issuers and related regulatory expectations.
• Provide second-line oversight of compliance with licence conditions and the minimum criteria applicable to a licensed stablecoin issuer.
• Oversee regulatory obligations relating to the issuance, redemption and offering of specified stablecoins and support controls to prevent unlicensed or non-compliant regulated activities. Sanctions Compliance
• Act as a subject matter expert on sanctions compliance programme, including customer, counterparty, transaction and wallet screening, where applicable.
• Monitor relevant developments in sanctions regimes and assess their impact on the firm.
• Review sanctions alerts and provide risk-based advice to the business. Fraud Risk Management
• Act as a subject matter expert to provide oversight of internal, external, payment and third-party fraud risks.
• Coordinate or oversee investigations into suspected fraud incidents.
• Monitor fraud trends, typologies and indicators and recommend control enhancements. Anti-Bribery and Corruption
• Act as a subject matter expert to ABC policies, standards and procedures.
• Provide advice on gifts and entertainment, conflicts of interest, intermediaries and third-party risks.
• Review higher-risk intermediary and third-party relationships. Governance and Reporting
• Prepare FCC management information, risk metrics and committee reports.
• Present material FCC matters to senior management, the Board and relevant governance committees.
• Escalate material financial crime risks, incidents and regulatory issues. Training and Awareness
• Develop and deliver FCC training for employees, management and directors.
• Promote a strong culture of compliance and financial crime risk awareness.
• Ensure mandatory FCC training requirements are appropriately assigned, completed and monitored. Qualifications Essential
• Bachelor’s degree in law, finance, risk management, accounting, compliance or a related field of studies.
• For Compliance Manager appointments, typically at least eight years of relevant FCC or compliance experience; for Director appointments, typically at least twelve years.
• Strong knowledge of the Stablecoins Ordinance, AMLO, HKMA requirements for licensed stablecoin issuers, AML/CFT, sanctions, fraud risk management, anti-bribery and corruption and compliance risk frameworks.
• Experience in banking, financial services, fintech, payment services, digital assets or a regulated stablecoin business.
• Demonstrated experience acting as an MLRO, Deputy MLRO or senior financial crime investigator, including the assessment and drafting of suspicious transaction reports.
• Proven ability to advise, challenge and coach first-line teams while maintaining effective second-line independence and accountability. Preferred
• CAMS, ICA or AAMLP/ CAMLP equivalent AML/FCC qualification.
• Cryptoasset, sanctions, fraud, legal or accounting qualifications, such as CCAS, CGSS, CFE, a legal qualification or a professional accounting qualification. Key Regulatory Frameworks
• Stablecoins Ordinance (Cap. 656).
• Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615).
• HKMA Guideline on Anti-Money Laundering and Counter-Financing of Terrorism (For Licensed Stablecoin Issuers).
• HKMA Guideline on Supervision of Licensed Stablecoin Issuers.
• Applicable sanctions, terrorist-financing, proliferation-financing, fraud and anti-bribery and corruption requirements. Key Competencies AML/CFT and sanctions
- Strategic thinking Compliance risk management
- Sound judgement and decision-making Regulatory interpretation
- Executive communication Policy and control development
- Stakeholder management and influence Investigations and escalation
- Team leadership and development Governance and reporting
- Integrity and professional courage Role Accountability
• Maintaining an effective and proportionate FCC control framework.
• Supporting compliance with applicable financial crime laws, regulations and regulatory expectations.
• Providing independent oversight, challenge and escalation of financial crime risks.
• Protecting the firm from legal, regulatory, financial and reputational harm arising from financial crime exposure.
• Supporting the firm’s continued compliance with the Stablecoins Ordinance, AMLO, licence conditions and applicable HKMA guidelines.